Common Employee Manual may link employers for Title VII jurisdiction

A federal District Court in Missouri has refused to grant summary judgment to dismiss federal retaliation claims against a church and its low-income housing affiliates, even though the employee’s direct employer had only 5 employees and not the 15 employees required to create federal jurisdiction under Title VII.  The Court said there was a substantial question of fact about whether the 45-55 employees of the church should be considered in determining jurisdiction.